DECISION

 

Waymo LLC v. Hong Jun Jia

Claim Number: FA2605002222089

 

PARTIES

Complainant is Waymo LLC ("Complainant"), represented by Griffin Barnett of Morgan, Lewis & Bockius LLP, District of Columbia, USA. Respondent is Hong Jun Jia ("Respondent"), China.

 

REGISTRAR AND DISPUTED DOMAIN NAME

The domain name at issue is <waymoos.com>, registered with Chengdu West Dimension Digital Technology Co., Ltd.

 

PANEL

The undersigned certifies that they have acted independently and impartially and to the best of their knowledge have no known conflict in serving as Panelist in this proceeding.

 

Héctor Ariel Manoff as Panelist.

 

PROCEDURAL HISTORY

Complainant submitted a Complaint to Forum electronically on May 19, 2026; Forum received payment on May 19, 2026.

 

On May 20, 2026, Chengdu West Dimension Digital Technology Co., Ltd. confirmed by e-mail to Forum that the <waymoos.com> domain name is registered with Chengdu West Dimension Digital Technology Co., Ltd. and that Respondent is the current registrant of the name.  Chengdu West Dimension Digital Technology Co., Ltd. has verified that Respondent is bound by the Chengdu West Dimension Digital Technology Co., Ltd. registration agreement and has thereby agreed to resolve domain disputes brought by third parties in accordance with ICANN's Uniform Domain Name Dispute Resolution Policy (the "Policy").

 

On May 21, 2026, Forum served the Complaint and all Annexes, including a Chinese and English Written Notice of the Complaint, setting a deadline of June 10, 2026 by which Respondent could file a Response to the Complaint, via e-mail to all entities and persons listed on Respondent's registration as technical, administrative, and billing contacts, and to postmaster@waymoos.com. Also, on May 21, 2026, the Chinese and English Written Notice of the Complaint, notifying Respondent of the e-mail addresses served and the deadline for a Response, was transmitted to Respondent via post and fax, to all entities and persons listed on Respondent's registration as technical, administrative and billing contacts.

 

A timely Response was received and determined to be complete on June 9, 2026.

 

Additional Submission by Complainant was received on June 12, 2026.

 

On June 9, 2026, pursuant to Complainant's request to have the dispute decided by a single-member Panel, Forum appointed Héctor Ariel Manoff as Panelist.

 

Having reviewed the communications records, the Administrative Panel (the "Panel") finds that Forum has discharged its responsibility under Paragraph 2(a) of the Rules for Uniform Domain Name Dispute Resolution Policy (the "Rules") "to employ reasonably available means calculated to achieve actual notice to Respondent" through submission of Electronic and Written Notices, as defined in Rule 1 and Rule 2.

 

RELIEF SOUGHT

Complainant requests that the domain name be transferred from Respondent to Complainant.

 

PRELIMINARY ISSUE: LANGUAGE OF PROCEEDING

According to the Registrar, the registration agreement is written in Chinese. Rule 11(a) provides that the language of the proceedings is the language of the registration agreement, subject to the authority of the Panel to determine otherwise, having regard to the circumstances of the case. Complainant filed its Amended Complaint in English and requests that these proceedings be conducted in English.

 

The Panel finds persuasive evidence to suggest the likely possibility that Respondent is to a material degree conversant and proficient in the English language taking into account that the Response filed is in English.

 

In addition, Respondent does neither challenge the language used in the complaint nor the request to get a decision in English.

 

Moreover, the evidence submitted by Complainant (Exhibit H) shows the domain for sale with the offer also in English.

 

Complainant and their representative do not understand Chinese and since there has been no response to the complaint and Respondent has not objected that it could not read or understand the complaint, the Panel finds that in the circumstances it is appropriate for these proceedings to continue in the English language.

 

PARTIES' CONTENTIONS

A. Complainant

1- Complainant, Waymo LLC, owns famous WAYMO mark registered in China and USA since at least 2019.

2- The trademark has been used in connection with autonomous vehicle technology and related vehicle, transportation and logistics offerings since 2016.

3- Complainant has spent significant time, money and resources promoting its WAYMO mark.

4- The disputed domain is identical or confusingly similar to Complainant's WAYMO mark, it incorporates the mark in its entirety, merely adding the descriptive term "OS" (a common abbreviation for "operating system") and the ".com" generic top-level domain ("gTLD").

5- Respondent has no rights or legitimate interests in the disputed domain.

6- Respondent registered and used the disputed domain name in bad faith.

7- Respondent benefits from the disputed domain by diverting Internet users looking for Complainant and its goods and services to Respondent's own website advertising the disputed domain for sale.

8- Respondent appears to own a portfolio of other domain names incorporating third-party brands which demonstrates cybersquatting.

 

B. Respondent

1- The domain <waymoos.com> is phonetically split into two independent syllables: way-moos with clear differences in spelling, pronunciation and overall meaning from the complainant's trademark WAYMO.

2- The additional "moos" suffix creates a distinct sound and visual structure.

3- The domain name <waymoos.com> was registered on February 3, 2026, and since registration, the domain name has not been offered for sale.

4- The disputed domain name has not been used to mislead internet users, divert customers, conduct phishing activities, disrupt the Complainant's business.

5- No evidence has been presented showing any bad-faith use of the

disputed domain name.

6- Waymo had only a few scattered industry updates in mainland China, with no mainstream viral reports or large-scale public discussions.

 

C. Complainant's additional submissions

1- Complainant argues that the test for identity or confusing similarity under the first element of the Policy involves a side-by-side comparison of the domain name and the textual components of the relevant trademark to assess whether the mark is recognizable within the disputed domain name.

2- Complainant notes that "way moos" has no common or descriptive meaning as a phrase, it just reflects the identical WAYMO mark + "OS" (operating system software) and/or as a mere typo of "Waymos".

3- The domain does not include a hyphen between the "way" and "moos" elements.

4- Respondent has not challenged the evidence showing the domain for sale and even if it had, the non-use of a domain name is a bad faith sign under the doctrine of passive holding.

 

FINDINGS

Waymo LLC is a company which owns trademark WAYMO registered in USA and China and the domain name <waymo.com> and uses them in connection with autonomous vehicle technology and related vehicle, transportation and logistics offerings since 2016. Respondent registered the disputed domain name, <waymoos.com>, in 2026. Respondent registered and is using the domain name in bad faith.

 

DISCUSSION

Paragraph 15(a) of the Rules instructs this Panel to "decide a complaint on the basis of the statements and documents submitted and in accordance with the Policy, these Rules and any rules and principles of law that it deems applicable."

 

Paragraph 4(a) of the Policy requires that Complainant must prove each of the following three elements to obtain an order that a domain name should be cancelled or transferred:

 

(1)       the domain name registered by Respondent is identical or confusingly similar to a trademark or service mark in which Complainant has rights; and

(2)       Respondent has no rights or legitimate interests in respect of the domain name; and

(3)       the domain name has been registered and is being used in bad faith.

 

Identical and/or Confusingly Similar

Complainant owns trademark rights on WAYMO in USA and China (Exhibit E) and uses it since 2016.

 

Complainant also provided evidence of the use on its website <www.waymo.com> (Exhibit G) and evidence regarding third-party websites demonstrating the value of complainant's WAYMO trademark (Exhibit F).

 

The disputed domain name incorporates Complainant's WAYMO mark in its entirely with the only addition of the descriptive term "OS" (a common abbreviation for "operating system") and the ".com" generic top-level domain ("gTLD").

 

Respondent argues that the domain <waymoos.com> is phonetically split into two independent syllables: way-moos with clear differences in spelling, pronunciation and overall meaning from the complainant's trademark WAYMO and that the additional "moos" suffix creates a distinct sound and visual structure.

 

However, the Panel agrees with Complainant that since the domain name does not include a hyphen between way and moos, it is not likely that consumers consider that the disputed domain name includes two syllables/words: way and moos.

 

The Panel concludes that the disputed domain name is confusingly similar to Complainant's mark since the additional elements are not sufficiently distinctive. See Microsoft Corporation v. Thong Tran Thanh, FA 1653187 (Forum Jan. 21, 2016) (determining that confusing similarity exists where [a disputed domain name] contains Complainant's entire mark and differs only by the addition of a generic or descriptive phrase and top-level domain, the differences between the domain name and its contained trademark are insufficient to differentiate one from the other for the purposes of the Policy); see also, Bloomberg Finance L.P. v. Nexperian Holding Limited, FA 1782013 (Forum June 4, 2018) ("Where a relevant trademark is recognizable within a disputed domain name, the addition of other terms (whether descriptive, geographical, pejorative, meaningless, or otherwise) does not prevent a finding of confusing similarity under the first element.").

 

The Panel finds that the domain name is identical and confusingly similar to Complainant marks under Policy ¶ 4(a)(i).

 

Rights or Legitimate Interests

Complainant argues Respondent has no rights or legitimate interests in the disputed domain name because Respondent is not commonly known by the disputed domain name and Complainant has never licensed rights to or authorized Respondent to use the WAYMO mark.

 

The Panel finds that Respondent is not commonly known by the <waymoos.com> domain name. Under Policy ¶ 4(c)(ii), relevant WHOIS information, among other evidence, may demonstrate that Respondent is not commonly known by the disputed domain name. See Chevron Intellectual Property LLC v. Fred Wallace, FA 1626022 (Forum July 27, 2015) (finding that the respondent was not commonly known by the <chevron-europe.com> domain name under Policy ¶ 4(c)(ii), as the WHOIS information named "Fred Wallace" as registrant of the disputed domain name).

 

In this case, according to the information provided, Respondent is mentioned as Hong Jun Jia and Respondent has not submitted evidence on the contrary. Thus, the Panel concludes that the Respondent is not commonly known by the disputed domain name per Policy ¶ 4(c)(ii).

 

Further, Respondent has not submitted any evidence to prove it was authorized, licensed rights to, or otherwise permitted to use the WAYMO mark.

 

According to the evidence submitted (Exhibit H), Respondent's use of the <waymoos.com> domain is not a bona fide offering of goods. The website offers the domain for sale.

 

Respondent argued that the domain is not for sale but did not submit evidence in this respect.

 

Taking these facts into account this Panel concludes that the purpose of the disputed domain name is to try to show that the disputed domain name is associated with Complainant and that Respondent is not using the domain name in connection with a legitimate noncommercial use or fair use under Policy ¶ 4(c)(iii).

 

Therefore, the Panel agrees that Respondent is not commonly known by the disputed domain name does not have legitimate interest under Policy ¶ 4(a)(ii).

 

Registration and Use in Bad Faith

The Panel finds that the disputed domain name was registered after Complainant´s WAYMO trademark's first use (2016) and trademark registration date (2017) (Exhibit E). Respondent registered the domain in 2026 (Exhibit A).

 

Since the disputed domain name includes Complainant's trademark along with two letters which seem to refer to operating system, the Panel finds that Respondent had actual knowledge of Complainant's mark when registered the domain name and that registration was done in bad faith.

 

According to the evidence submitted by Complainant (Exhibit H), Respondent offered the domain name for sale. The Panel finds a bad faith sign in this fact. See Bank of Am. Corp. v. Nw. Free Cmty. Access, FA 180704 (Forum Sept. 30, 2003) ("Respondent's general offer of the disputed domain name registration for sale establishes that the domain name was registered in bad faith under Policy ¶ 4(b)(i).").

 

The Panel also points out that Respondent argued that the domain was not used in bad faith and that it was not offered for sale, but Respondent has neither submitted evidence nor included grounds to support it.

 

In addition, the disputed domain's homepage does not currently resolve to any active content; however, it can also be considered a bad faith sign. See Robert Half Inc. v. Rose Diaz / Robert half staffing, FA 2111371 (Forum Sept. 9, 2024), ("Respondent's passive holding of <rosediazroberthalfstaffing.org> demonstrates Respondent's bad faith registration and use pursuant to Policy ¶ 4(a)(iii)."); See also CommScope, Inc. of North Carolina v. Zhuang Yan / WANGYONG, FA 1764026 (Forum Feb. 14, 2018) ("Respondent's domain names do not have resolving websites. Using a domain name to resolve to an inactive website (or no website at all) indicates bad faith registration and use.").

 

Prior Panels have considered it reasonable to infer bad faith registration and use when facing conflicts involving inactive domain names without evidence of preparations for use. See Health Catalyst, Inc. v. Javid Henry, FA 2158701 (Forum July 1, 2025), ("Respondent registered a domain name incorporating Complainant's registered mark. Respondent does not appear to have made any active use of the domain name, nor to have engaged in preparations for such use, and has failed to come forward with any explanation for the selection of the name or its intended use. Under the circumstances, the Panel considers it reasonable to infer that Respondent registered the domain name intending to use it in a manner calculated to create and exploit confusion with Complainant and its mark, likely either by using the domain name to attract or defraud Internet users seeking Complainant or by selling the domain name to Complainant or a competitor, and that Respondent is maintaining the domain name for that purpose. See, e.g., Blink Health Inc. v. Asif Khan / BlinkRXhealth, supra (finding bad faith registration and use in similar circumstances). The Panel finds that the disputed domain name was registered and is being used in bad faith.").

 

In addition, Complainant argues that Respondent appears to own a portfolio of other domain names incorporating third-party brands which demonstrates cybersquatting (Exhibit I).

 

Respondent has not challenged this ground or submitted evidence on the contrary.

 

This Panel concludes that Respondent has registered the domain name with the intent to attract and divert Internet users to the corresponding website for its own benefit. See Carey Int'l, Inc. v. Kogan, FA 486191 (Forum July 29, 2005) ("[T]he Panel finds that Respondent is capitalizing on the confusing similarity of its domain names to benefit from the valuable goodwill that Complainant has established in its marks. Consequently, it is found that Respondent registered and used the domain names in bad faith under Policy ¶ 4(b)(iv)."). 

 

The Panel determines that Respondent registered and used the disputed domain name in bad faith under Policy ¶ 4(a)(iii).

 

DECISION

Having established all three elements required under the ICANN Policy, the Panel concludes that relief shall be GRANTED.

 

Accordingly, it is Ordered that the <waymoos.com> domain name be TRANSFERRED from Respondent to Complainant.

 

 

 

Héctor Ariel Manoff, Panelist

Dated: June 22, 2026